In the first sentence of the preface, Mr Bools captures the essence of his work: “This book sets out to be a detailed comparison of the English and American law of ocean bills of lading and is restricted to the document of title aspect of these” (p. ix). As promised, the analysis is meticulously detailed. Mr Bools carefully considers and discusses possible interpretation and nuances of clauses in statutes that have twice been superseded. This level of detail is possible, of course, only because the scope of the study is strictly limited. In an era when much of the modern scholarship in the field examines broader aspects of bills of lading and their substitutes, the present work is indeed “restricted” to a narrow aspect of the subject. But there is one inaccuracy in the topic sentence. Notwithstanding the broad reference to “American law,” the United States is the only country in the Americas whose law is actually discussed.

The book begins with a brief historical introduction, tracing the bill of lading from its medieval origins to the end of the 18th century. The developments of the 19th and early 20th centuries are then discussed in detail, with particular emphasis on how US law moved away from its English origins. Subsequent chapters focus on particular aspects of the subject, such as when a bill of lading gives a transferee better title than the transferor had, the extent to which a bill of lading permits a holder to bring a claim against the issuer, and the effect of representations in the bill of lading. Each of these discussions is fully comparative, with detailed consideration of both English and US law.

The comparative discussion makes a valuable contribution to understanding on both sides of the Atlantic. For roughly a century, England and the United States have taken fundamentally different approaches to the bill of lading. While English law generally sees the bill of lading as a substitute for the goods, the US treatment is more analogous to a negotiable instrument. Thus each system has addressed problems from different perspectives. Examining these differing approaches generates insights that enable the reader better to understand each system.

Unfortunately, any foray into comparative law carries risks, particularly for an author with strong expertise in one legal system who writes about another in which he has not been trained. These risks are less serious when the systems are as similar as those of England and the United States. But the similarities also lull authors into a false sense of security, thus making it more likely that the unsuspecting will fall into the traps that still exist. Despite the author’s extensive research into the US sources, he has taken a very English approach in interpreting them. It is almost as if he were describing how the US statutes and decisions would be construed if the US judiciary were suddenly filled with English judges. United States law has been so heavily influenced by the legal realist movement that English legal methods do not always capture the sense of US law.

The author’s relative unfamiliarity with US legal methods also reveals itself in comparatively minor but still annoying ways. Except in a few places, he seems to have little appreciation for the differences among US courts. He accordingly cites judicial decisions without identifying the court, leaving readers to guess the court from the reporter. While some series of reports are unambiguous (such as those publishing only US Supreme Court decisions), most are not. To offer but one example, the table of cases cites 23 decisions to the Pacific Reporter without further identification. They are from 15 different courts in 10 different States.

Unfortunately, the reader who wishes to go back to the original reports and personally review the sources quickly learns that the citations are not only incomplete but too often inaccurate. Errors include mistyped case names, volume numbers, reporter abbreviations, page numbers, and dates. Subsequent appellate history is generally (but not always) omitted, thus failing to inform readers of at least one case that was reversed on appeal over 10 years before the book was published. It appears that only eight US Supreme Court decisions are cited, but the citations for seven of them are